I still find it hard to believe that there are some companies out there that haven’t heard of the Globally Harmonized System of Classification and Labeling (GHS). It’s hard for me to believe this, because in three months’ time everyone who works with hazardous chemicals in the workplace will have to be trained (and no I’m not kidding). December 1st, 2013 is the deadline to have all employees trained on the GHS within OSHA, yet somehow I still show up to companies to train their workers on shipping dangerous goods (this often involves employees who are in the EHS department) and I ask them if they have heard of GHS or OSHA HazCom 2012. To my surprise I still get the blank stares and the question “What is that?”. This really isn’t a bad thing for me because that means I get to help one of our clients avoid fines by informing them about more training they will need, and in many cases they have ICC train them in GHS within OSHA as well.
The GHS is what OSHA has adopted for its new Hazard Communication Standard and it was adopted in 2012 which is why the standard is called OSHA HazCom 2012. This new standard is meant to try and “harmonize” hazardous chemical communications around the globe. Before we go any further I want to inform you that the GHS and OSHA HazCom 2012 are NOT the same thing. The GHS is a recommendation that was developed at the “Earth Summit” in 1992 in Brazil by the United Nations (UN), and it encompasses the classification of chemicals, SDSs, labels, and training. OSHA HazCom 2012 are the pieces of GHS that OSHA has adopted plus other hazards that were not part of the GHS.
The major change that is happening with the adoption of the GHS within OSHA is going to be the classification of chemicals. The classification will drive the standard phrases that will appear on the SDS (changed from MSDS) and also appear on the drum labels. Under the old system there was very little information that needed to be provided on an SDS and each country had different standards for how they wanted chemicals classified. Depending on the chemical that was being shipped there could be a classification of toxic in one country, flammable in another, and flammable and toxic in a third. This caused chemical manufacturers to need at least three MSDSs for that one product. As you can imagine, this caused nightmares for chemical companies who wanted to be competitive on a global market.
Now, I know what you are thinking “if the GHS is adopted then won’t that fix these problems?”, and the simple answer to that is “no”, not necessarily. As I mentioned earlier the GHS is just a recommendation that the UN would like you to follow, but it is no way mandatory. What this means is that countries are free to adopt any portion of the GHS that they would like in fact they do not have to adopt any portion of the GHS if they do not want to. The United States did just that, they adopted portions of the GHS, and they added extra hazards (hazards not otherwise classified) to it as well. Not only is the GHS optional but the U.N. is updating the recommendations every two years and not every country is updating alongside the U.N.. The U.S. decided to use the 3rd revision of the GHS which was published in 2009, and in June of 2013 the U.N. published the 5th revision of the GHS, so the U.S. is a little behind.
The question we should really be asking ourselves is “Will the GHS improve workers knowledge of the hazards associated with the chemicals in the workplace?” and in my honest opinion I believe that the implementation of these recommendations will produce a more knowledgeable workforce who will be able to keep themselves safe when using hazardous chemicals in the workplace. Not only do I believe in the safety and knowledge that the GHS brings, but I also believe that with time, many more countries will adopt these recommendations which will transition us into a “Globally Harmonized System” where we will no longer need 3 SDSs (or more) for one product.
For those of you that have stuck with me this long I can only assume (and we all know what assuming makes us) that you are interested in the GHS and want more information. Well, if I am correct and you do want more information, then you have come to the right place. We are here to help you understand what is required of you to make this a smooth transition, whether it be classifying chemicals and authoring an SDS for them or maybe you just need to be trained so you can understand what is required of you, either way we will keep you up to date on your GHS needs. Give 888-442-9628 a call if you are confused about GHS or you want more information on training or services.
Transport Canada has posted a bulletin for shipping infectious substances (RDIMS#8210418).
In the overview, Transport Canada reviews what an infectious substance is: anything that is known or reasonably believed to cause disease in humans or animals. This substance can be in blood, body fluids, body parts, organs, tissue or cultures. The responsibility of the consignor is to: train, classify, package, mark/label, document, placard and have an ERAP in place, if necessary. In addition to the definition found in section 1.4 of TDG (Transportation of Dangerous Goods Regulations), the Public Health Agency of Canada (PHAC) has regulations that apply to lab safety and the import of human pathogens into Canada. Please keep in mind that provincial governments may have additional regulations in place.
Classification of infectious substances is generally done by a medical professional. If you know that what you want to ship is an infectious substance, then it is class 6.2. In TDG, under Appendix 3 in Part 2 is a listing of regulated infectious substances. This list is not exhaustive. If what you want to ship is not on the list, but exhibits the characteristics of an infectious substance, then it is class 6.2.
The authorized shipping names in TDG are:
UN2814 Infectious substance, affecting humans,
UN2900 Infectious substance, affecting animals
UN3373 Biological substance, Category B
UN3291 Clinical waste, unspecified, n.o.s., (Bio)Medical waste, n.o.s., or Regulated medical waste, n.o.s. are not listed in TDG. These shipping names can be used utilizing section 1.10 of TDG. It is recommended to use Type 1C packaging.
When shipping infectious substances, you must do so in compliance with TDG. When shipping by air, you must use the ICAO Technical Instructions and by sea, the International Maritime Dangerous Goods Code (IMDG). Please note that competent authority approval may be needed.
There are exemptions available for shipping within Canada:
section 1.39 – Class 6.2, Infectious Substances, Category B Exemption
section 1.41 – Biological Products Exemption
section 1.42 – Human or animal Substance Believed not to Contain Infectious Substances Exemption
section 1.42.1 – Tissues or Organs for Transplant Exemption
section 1.42.2 – Blood or Blood Components Exemption
Quick reference guide for road transport
Infectious Substance, Affecting Humans
Infectious Substance, Affecting Animals
Biological Substance, Category B
UN2814 or UN2900 if waste contains Category A.
UN3291 if waste contains Category B.
Type 1B (only in certain instances. Refer to TDG 5.16)
Type 1A, or
Type 1B, or
No, if shipped in accordance with the exemption in TDG 1.39
Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?
Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:
A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
Employees may not perform functions without appropriate training
Training may be provided by the hazmat employer or other public or private sources
A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered
Hazmat employee training must include the following:
General awareness/familiarization training
Security awareness training
In-depth security training
Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.
For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.
Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.
Call 888.442.9628 for more information. Have a problem? We have a solution.
ICC Compliance Center is excited to announce training dates for courses related to OSHA’s Hazcom 2012 (GHS standard). Classes are scheduled in our Niagara Falls, NY and Houston, TX training centers, and are soon to be scheduled around the country in the fall. We have four classes to choose from: A half-day General Awareness class; a one day “What’s Changed?”; a two day Manager/Supervisor class and a three day GHS Classification class. On-site training classes and webinars will be available soon.
We have four classes to choose from, depending on your interest. A half-day General Awareness, a one day What’s Changed, a two day Manager/Supervisor and a three day GHS Classification class.
Over the past few decades, the United Nations (UN) has been attempting to create a system with similar goals, that would be used (with possible minor modifications) on a world-wide scale. This system is called the Globally Harmonized System, or GHS.
OSHA has responded by modifying the hazard communication standard to reflect many of the concepts found in the GHS. These elements include: classification of hazardous substances, information to be provided on labels, and information to be found on material safety data sheets (or, as the GHS calls them, safety data sheets).
Training is the first deadline in the phased in final rule that was effective May 26, 2012. Training on the new elements must be completed by Dec 1, 2013.
ICC Compliance Center is proud to introduce onsite training in the Houston area. We currently provide various types of hazardous materials/dangerous goods training and certification to meet our customers’ requirements, including live-classroom, web-based or instructor-led webinars and onsite training.
Our regulatory specialists will come to a location of your choice, eliminating any travel expenses for your employees (ex. gas, airfare, hotel, rental car and dining).
Our experienced staff can develop and deliver many types of programs created especially for your company’s individual dangerous goods and hazardous materials requirements (products, modes of transport, shipping systems, etc.), together with practical suggestions for effective implementation.
Customized Onsite Training Gives You Control Over:
Class location, size and audience
Class schedule – schedule the training around your company’s workload
Confidential information – With only your employees present, sensitive and proprietary issues can be addressed and used as examples during class
Course retention – Studies have proven workers are able to learn more when they study together. The effects of a shared training experience continue long after the seminar has ended
David Lyle Ford has recently joined our team as a Regulatory Specialist, and specializes in dangerous goods, i.e. CFR 49, TDG, IATA, and IMDG. David came to ICC from a global petrochemical manufacturer where he was responsible for all modes of transport including railroad, highway, sea and air, with bulk and non-bulk transportation containers.
In addition to teaching regulations for CFR 49, TDG, IATA, and IMDG, David will utilize his strong experience to assist you and your team with:
Handling the complexities of trans-loading and help you reduce the liability and safety risks involved in bulk transport,
Preparing for an emergency incident before it happens. This includes assisting you in creating a plan that ensures employers and workers have the necessary equipment, know where to go, and know how to keep safe when an emergency occurs
David’s vision is to provide training that is easy to understand and guidance on how to ship dangerous goods safely.